filed state of california medical board· of california …4patientsafety.org/documents/rai,...

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KAMALA D. HARRIS Attorney General of California VLADIMIR SHALKEVICH Acting Supervising Deputy Attorney General JOHN S. GATSCHET Deputy Attorney General State Bar No. 244388

California Department of Justice 1300 I Street, Suite 125 P.O. Box 944255 Sacramento, CA 94244-2550 Telephone: (916) 445-5230 Facsimile: (916) 327-2247

Attorneys for Complainant

FILED STATE OF CALIFORNIA

MEDICAL BOARD· OF CALIFORNIA SACRAMENTO ftuc?J. 04 20 ..L.k.. BY .1) 1. I t.h N d ') ANALYST

BEFORE THE MEDICAL BOARD OF CALIFORNIA

DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

In the Matter of the Accusation Against:

Meetinder Kaur Rai, M.D. 1930 EAST HATCH RD., STE. A MODESTO , CA 95351

Physician's and Surgeon's Certificate No. A 49556,

Respondent.

Complainant alleges:

PARTIES

Case No. 800-2013-002158

ACCUSATION

1. Kimberly Kirchmeyer ("Complainant") brings this Accusation solely in her official

20 capacity as the Executive Director ofthe Medical Board of California, Department of Consumer

21 Affairs ("Board").

22 2. On or about June 11, 1991, the Medical Board issued Physician's and Surgeon's

23 Certificate Number A 49556 to Meetinder Kaur Rai, M.D. ("Respondent"). The Physician's and

24 Surgeon's Certificate was in full force and effect at all times relevant to the charges brought

25 herein and will expire on October 31, 2018, unless renewed.

26 JURISDICTION

27 3. This Accusation is brought before the Board, under the authority of the following

28 laws. All section references are to the Business and Professions Code unless otherwise indicated.

1

(MEETINDER KAUR RAI, M.D.) ACCUSATION NO. 800-2013-002158

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4. Section 2227 of the Code provides, in pertinent part, that a licensee who is found

guilty under the Medical Practice Act may have his or her license revoked, suspended for a period

not to exceed one year, placed on probation and required to pay the costs of probation monitoring,

or such other action taken in relation to discipline as the Board deems proper..

5. Section 2234 of the Code, states, in pertinent part:

"The board shall take action against any licensee who is charged with unprofessional

conduct. In addition to other provisions of this article, unprofessional conduct includes, but is not

limited to, the following:

"(a) Violating or attempting to violate, directly or indirectly, assisting in or abetting the

violation of, or conspiring to violate any provision of this chapter.

"(b) Gross negligence.

"(c) Repeated negligent acts. To be repeated, there must be two or more negligent acts or

omissions. An initial negligent act or omission followed by a separate and distinct departure from

the applicable standard of care shall constitute repeated negligent acts.

"(1) An initial negligent diagnosis followed by an act or omission medically appropriate

for that negligent diagnosis of the patient shall constitute a single negligent act.

"(2) When the standard of care requires a change in the diagnosis, act, or omission that

constitutes the negligent act described in paragraph (1 ), including, but not limited to, a

reevaluation of the diagnosis or a change in treatment, and the licensee's conduct departs from the

applicable standard of care, each departure constitutes a separate and distinct breach of the

standard of care.

'' ~'

6. Section 2266 of the Code states:

"The failure of a physician and surgeon to maintain adequate and accurate records relating

to the provision of services to their patients constitutes unprofessional conduct."

Ill

Ill

Ill

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1 FIRST CAUSE FOR DISCIPLINE

2 (Gross Negligence)

3 7. Respondent's license is subject to disciplinary action under section 2234, subdivision

4 (b), of the Code in that Respondent was grossly negligent in the treatment of five patients, R.A.,

5 W.B., V.G., L.M., and E.M., 1 because she falsified medical records by documenting identical

6 patient complaints. The circumstances are as follows:

7 Patient R.A.

8 8. The Medical Board reviewed the complete treatment and billing records of Patient

9 R.A. between February 25, 2013, and June 12, 2015. During that period of time, Respondent saw

10 R.A. at 27 treatment visits.

11 9. Respondent documented a comprehensive physical exam at all 27 visits despite

12 seeing the patient every two weeks. On repeated occasions the patient's complaints and physical

13 findings were identical.

14 10. On February 27,2013, Respondent documented that, "patient is complaining of heart

15 pounding for one week. Heart pounding is severe, intermittent, increases with exertion, is

16 relieved with rest." On January 13, 2014, March 13, 2014, August 7, 2014, and June 12, 2015,

1 7 Respondent documented the exact same complaint with an identical description.

18 11. On January 27, 2014, Respondent documented that patient's mouth examination

19 showed, "lips, teeth, and gums have no sign of infection. Posterior pharyngeal wall is congested

20 on the right with a whitish exudate." On April30, 2014, Respondent documented the exact same

21 mouth examination with an identical description.

22 12. On June 10,2014, Respondent documented that, "patient is complaining of an itchy

23 rash on the body for one week. Itching is moderate, intermittent, increases at night, is not

24 relieved with over-the-counter medication. No fever, chills." On July 14, 2014, and September

25 10, 2014, Respondent documented the exact same complaint with an identical description.

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28 1 All witnesses will be fully identified in discovery.

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13. On June 12, 2013, Respondent documented that, "patient is complaining of lower

2 back pain for a few months. Pain is moderate, intermittent, increases on movements. No

3 radiation of the pain." Respondent documented the musculoskeletal exam by noting, "[r]ange of

4 motion decreased in the lumbosacral area with a muscle spasm present bilaterally." On February

5 10,2014, April4, 2014, April 17,2014, May 28,2014, September 10,2014, and October 23,

6 2014, Respondent documented the exact same complaint and musculoskeletal examination with

7 an identical description.

8 14. On September 25, 2014, Respondent documented the musculoskeletal exam by

9 noting, "[s]pine has bilateral paravertebral tenderness noted, especially in the L1-L5 level. Range

10 of motion decreased on the lumbosacral area with a muscle spasm present bilaterally." On

11 December 2, 2014, December 15, 2014, and December 29, 2014, Respondent documented the

12 musculoskeletal exam with an identical description.

13 15. Respondent's treatment ofR.A. as described above represents a separate and distinct

14 extreme departure from the standard of care by documenting identical patient complaints and

15 identical physical exams without accurately reflecting the actual exam that she performed. In

16 addition, assuming that Respondent was accurately documenting her care ofR.A., Respondent's

17 repeated failure to consider, modify and/or document how the patient was progressing, and/or

18 document whether she was considering or modifying treatment despite R.A.' s repeated identical

19 patient complaints represents a separate and distinct extreme departure from the standard of care.

20 Patient W.B.


22 W.B. between February 22,2013, and June 8, 2015. During that period of time, Respondent saw

23 R.A. at 43 treatment visits.




27 18. On April15, 2014, Respondent documented that, "patient is complaining ofheart

28 pounding for one week. Heart pounding is severe intermittent, increases with exertion, is relieved

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1 with rest." On August 11, 2014, Respondent documented the exact same complaint with an

2 identical description. On February 3, 2015, Respondent documented the exact same complaint

3 with an identical description for a two week period of time rather than a one week period.

4 19. On February 25, 2013, Respondent documented that "patient is complaining of

5 cough." Respondent documented that W.B.'s mouth examination as showing, "(l)ips, teeth, and

6 gums have no signs of infection. Posterior pharyngeal wall is congested on the right with a

7 whitish exudate." On August 23, 2013, November 6, 2013, December 5, 2013, May 13, 2014,

8 and June 8, 2015, Respondent documented the exact same mouth examination with an identical

9 description.

10 20. On February 12,2013, Respondent documented that, "patient is complaining of lower

11 back pain for a few months. Pain is moderate, intermittent, increases on movements. No radiation

12 ofthe pain." Respondent documented the musculoskeletal exam by noting, "Range of motion

13 decreased in the lumbosacral area with a muscle spasm presents bilaterally." On May 31, 2013,

14 August 9, 2013, September 16,2013, October 14, 2013, October 23, 2013, November 20,2013,

15 December 5, 2013, December 12, 2013, December 30,2013, March 10,2014, April15, 2014,

16 April29, 2014, June 13,2014, July 15,2014, July 29,2014, and August 25,2014, Respondent

17 documented the exact same musculoskeletal examination with an identical description.

18 21. On September 15,2014, Respondent documented that, "patient is complaining of

19 lower back pain for a few months. Pain is moderate, intermittent, increases on movements. No

20 radiation of the pain. It only gets relieved with Norco. Otherwise patient is non-functional."

21 Respondent documented the musculoskeletal exam by noting, "[ s ]pine has bilateral paravertebral

22 tenderness noted, especially at the L 1 - L5 level. Range of motion decreased in the lumbosacral

23 area with a muscle spasm present bilaterally." On September 29, 2014, October 21, 2014,

24 November 4, 2014, November 18, 2014, and December 2, 2014, documented the exact same

25 complaint and the exact same musculoskeletal examination with an identical description.

26 22. On January 8, 2015, Respondent documented that, "patient is complaining of lower

27 back pain for a few months. Pain is moderate to severe, intermittent, increases on movements."

28 Respondent documented the musculoskeletal exam by noting, "LS spine is tender to touch from

5

(MEETINDER KAUR RAJ, M.D.) ACCUSATION NO. 800-2013-002158

1 L1- L5. Range of motion decreased." On March 3, 2013, March 17,2015, April6, 2015, April

2 20,2015, May 4, 2015, and June 8, 2015, documented the exact same complaint and the exact

3 same musculoskeletal examination with an identical description.

4 23. Respondent's treatment ofW.B. as described above represents a separate and distinct



7 addition, assuming that Respondent was accurately documenting her care ofW.B., Respondent's


9 document whether she was considering or modifying treatment despite W.B. 's repeated identical

10 complaints with no improvement represents a separate and distinct extreme departure from the

11 standard of care.

12 Patient V.G.


14 V.G. between February 13, 2013, and June 11, 2015. During that period of time, Respondent saw

15 V.G. at 41 treatment visits.

16 25. Respondent documented a comprehensive physical exam at all41 visits despite



19 26. On September 9, 2013, Respondent documented that, "patient is complaining of heart


21 relieved with rest." On April4, 2013, and February 19,2015, Respondent documented the exact

22 same complaint with an identical description.

23 27. On May 24, 2013, Respondent documented Patient V.G.'s mouth examination as

24 follows, "Lips, teeth, and gums have no sign of infection. Posterior pharyngeal wall is congested

25 on the right with a whitish exudate." Respondent documented Patient V.G.'s lung examination as

26 follows, "Breath sounds decreased bilaterally with scattered rhonci." On December 5, 2013, and

27 April 28, 2014, Respondent documented the exact same examinations with duplicate language.

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28. On February 13,2013, Respondent documented that, "patient is complaining of lower

2 back pain for a few months. Pain is moderate, intermittent, increases on movements. No


4 motion decreased in the lumbosacral area with a muscle spasm present bilaterally." On June 13,

5 2013, August 9, 2013, October 8, 2013, November 8, 2013, March 6, 2014, June 6, 2014, August

6 13, 2014, and September 24, 2014, Respondent documented the exact same complaint and

7 musculoskeletal examination with an identical and duplicate description.

8 29. On July 16, 2014, Respondent documented that, "patient is complaining of lower

9 back pain for a few months. Pain is moderate, intermittent, increases on movement. No radiation

10 of pain." Respondent documented the musculoskeletal exam by noting, "[r]ange of motion

11 decreased in the lumbosacral area with a muscle spasm present bilaterally. Spine has bilateral

12 paravertebral tenderness noted, especially at the L1- L5 level." On August 27,2014, and

13 September 10,2014, Respondent documented the exact same complaint and musculoskeletal

14 examination with an identical and duplicate description. On October 22, 2014, Respondent used

15 identical language with the exception of t1ipping two sentences in the paragraph.

16 30. On January 23,2015, Respondent documented the musculoskeletal exam by noting,

17 "LS spine is tender to touch from L1- L5. Range of motion decreased." On February 6, 2015,

18 March 5, 2015, March 17,2015, and April 16,2015, Respondent documented the exact same


20 31. On April 30, 2015, Respondent documented the musculoskeletal exam by noting, "LS

21 spine is tender to touch from L 1 - L5. Range of motion decreased with a muscle spasm." On

22 May 14, 2015, May 28,2015, and June 11,2015, Respondent documented the exact same


24 32. Respondent's treatment ofV.G. as described above represents a separate and distinct



27 addition, assuming that Respondent was accurately documenting her care ofV.G., Respondent's


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document whether she was considering or modifying treatment despite V.G.'s repeated identical


3 standard of care.

4 Patient L.M.


6 L.M. between January 3, 2013, and December 23,2015. During that period of time, Respondent

7 saw L.M. at 72 treatment visits.



1 0 findings were identical.

11 35. On June 12, 2013, Respondent documented that, "patient is complaining of heart


13 relieved with rest." On October 1, 2013, December 16, 2013, March 27,2014, May 19, 2014,

14 February 10, 2015, and May 28,2015, Respondent documented the exact same complaint with an

15 identical description.

16 36. On March 18,2013, Respondent documented that, "patient is complaining of cough.

17 Cough is moderate, intermittent, increases in night, is not relieved with over-the-counter cough

18 syrup." Respondent documented that the patient's mouth examination showed, "(l)ips, teeth, and

19 gums have no sign of infection. Posterior pharyngeal wall is congested on the right with a

20 whitish exudate." On October 29, 2013, January 13,2014, April22, 2014, November 4, 2014,

21 and March 10,2015, Respondent documented the exact same complaint with an identical

22 description.

23 37. On April29, 2013, Respondent documented the musculoskeletal exam by noting,

24 "[r]ange of motion decreased in the lumbosacral area with a muscle spasm present bilaterally."

25 On May 29, 2013, June 26, 2013, July 12, 2013, July 31, 2013, August 12, 2013, August 22,

26 2013, September 5, 2013, September 18,2013, October 14,2013, November 19,2013, December

27 3, 2013, December 30,2013, January 27,2014, February 10, 2014, March 3, 2014, March 13,

28 2014, March 27,2014, April10, 2014, May 6, 2014, June 6, 2014, September 2, 2014, February

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1 25,2015, and October 14,2015, Respondent documented the musculoskeletal examination with

2 an identical description.

3 38. On August 18, 2014, Respondent documented the musculoskeletal exam by noting,

4 "[s]pine has bilateral paravertebral tenderness noted, especially at the Ll- L5 level. Range of

5 motion decreased in the lumbosacral area." On September 16,2014, October 21,2014,

6 November 18, 2014, December 13,2014, and December 16, 2014, Respondent documented the

7 musculoskeletal examination with an identical description.

8 39. On April2, 2015, Respondent documented the musculoskeletal exam by noting, "LS

9 spine is tender to touch from Ll- L5. Range of motion decreased with a muscle spasm." On

10 April17, 2015, April30, 2015, May 13, 2015, May 28, 2015, and June 25, 2015, Respondent

11 documented the musculoskeletal examination with an identical description.

12 40. On July 21, 2015, Respondent documented the musculoskeletal exam by noting, "LS

13 spine is tender to touch from Ll - L5. Range of motion decreased with a muscle spasm present."

14 On August 20, 2015, September 2, 2015, September 16, 2015, October 27, 2015, November 12,

15 2015, December 10, 2015, and December 23,2015, Respondent documented the musculoskeletal

16 examination with an identical description.

1 7 41. Respondent's treatment of L.M. as described above represents a separate and distinct



20 addition, assuming that Respondent was accurately documenting her care ofL.M. Respondent's


22 document whether she was considering or modifying treatment despite L.M. 's repeated identical



25 Patient E.M.


27 E.M. between August 9, 2013, and April 21, 2014. During that period of time, Respondent saw

28 E.M. at 18 treatment visits.

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1 4 3. Respondent documented a comprehensive physical exam at all 18 visits despite



4 44. On August 9, 2013, Respondent documented that, "patient is complaining ofheart


6 relieved with rest." On December 20, 2013, Respondent documented the exact same complaint

7 with an identical description.

8 45. On October 30, 2013, Respondent documented that, "patient is complaining of cough

9 for one week. Cough is intermittent, increases at night, is not relieved with over-the-counter

10 cough syrup." Respondent documented that the patient's mouth examination showed, "lips, teeth,

11 and gums have no signs of infection. Posterior pharyngeal wall is congested on the right with a

12 whitish exudate." Respondent documented that the patient's lung examination showed, "(b )reath

13 sounds decreased bilaterally with scattered rhonchi." On April 8, 2014, Respondent documented

14 the exact same complaint and documented the exact same mouth and lung examination with an

15 identical description.

16 46. On August 22, 2013, Respondent documented that, "patient is complaining of lower

17 pack pain for a few months. Pain is moderate, intermittent, increases on movements. No


19 motion decreased in the lumbosacral area with a muscle spasm present bilaterally." On

20 September 18,2013, October 2, 2013, October 16, 2013, October 30,2013, November 13,2013,

21 November 25, 2013, December 9, 2013, December 20, 2013, January 2, 2014, February 20, 2014,

22 March 7, 2014, March 19, 2014, March 25, 2014, April 8, 2014, and April21, 2014, Respondent

23 documented the exact same musculoskeletal examination with an identical description.

24 47. Respondent's treatment ofE.M. as described above represents a separate and distinct



27 addition, assuming that Respondent was accurately documenting her care ofE.M., Respondent's


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1 document whether she was considering or modifying treatment despite E.M.' s repeated identical


3 standard of care.

4 48. On January 14, 2016, at an interview with the Board, Respondent stated that all

5 medical records are dictated. She denied that any of the medical records were created from

6 templates or cut and pasted from other documents.

7 49. Respondent documented that Patients R.A., W.B., V.G., L.M., and E.M. had

8 tenderness, muscle spasm, and decreased range of motion at every single visit that they reported

9 having back pain. Patients R.A., W.B., V.G., L.M., and E.M., never had a normal back exam

1 0 documented when they complained of back pain. When no complaint of back pain was made,

11 Respondent documented a normal back exam.


13 (b) of the Code in that she committed gross negligence by documenting identical patient

14 complaints and identical physical exams without accurately reflecting the actual exam that she

15 performed. In addition, assuming that Respondent was accurately documenting care,

16 Respondent's repeated failure to consider, modify and/or document how the patient was

17 progressing, and/or consider and/or document whether she was considering or modifying

18 treatment represents a separate and distinct extreme departure from the standard of care in

19 violation of section 2234, subdivision (b) of the Code.

20 SECOND CAUSE FOR DISCIPLINE

21 (Repeated Negligent Acts)


23 (c) of the Code in that she committed repeated negligent acts during the treatment ofPatient's

24 R.A., W.B., V.G., L.M., and E.M. The circumstances are as follows:

25 52. Paragraphs 7 through 50 are repeated here as more fully set forth above.

26 Patient R.A.

27 53. On January 23, 2013, Patient R.A. signed a Pain Management Contract with

28 Respondent that stated R.A. would not obtain any controlled medications from another doctor.

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On April 4, 2014, R.A. was seen in office by Respondent. Respondent prescribed Xanax2 and

2 Norco3. On AprilS, 2014, R.A. provided a urine specimen as part of a random drug screen. On

3 April 14, 2014, the urine drug screen was reported positive for three benzodiazepines4,

4 Nordiazepam, Oxazepam, and Temazepam, that Respondent was not prescribing to Patient R.A.

5 On April 17, 2014, R.A. was seen in office by Respondent. Respondent noted, "urine drug screen

6 was discussed with patient." Respondent did not note the inconsistent results of the drug screen,

7 and Respondent continued to prescribe Xanax and Norco.

8 54. Between February 27, 2013, and June 12, 2015, Respondent saw Patient R.A. in

9 office for a complaint of "heart pounding for one week" on five separate occasions. Respondent

10 only ordered EKGs and thyroid testing. Respondent did not refer R.A. to a Cardiologist or

11 perform any additional cardiac work-ups. Respondent did not document that she was unable to

12 refer R.A. to a Cardiologist or perform any additional work-ups because R.A. was a Medi-Cal

13 patient.

14 55. On June 10, 2014, July 14, 2014, and September 10, 2014, Respondent saw Patient

15 R.A. in office for a complaint of an "itchy rash on body for one week." The descriptions of the

16 rash and treatment for the rash were identical on all three occasions. Respondent continued to

17 prescribe hydrocortisone ointment despite the rash apparently not responding to treatment.

18 Respondent did not refer R.A. to a Dermatologist and/or Allergist. Respondent did not document

19 that she was unable to refer R.A. to a Dermatologist and/or Allergist because R.A. was a Medi-

20 Cal patient.

21 Patient W.B.

22 56. On September 30, 2013, Patient W.B. signed a Pain Management Contract with

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Respondent that stated W.B. would take her prescribed medication. On March 10,2014,

2 Xanax (Alprazolam) is a benzodiazepine used to treat people with anxiety. It is a Schedule IV controlled substance that carries a risk of misuse and chemical dependence.

3 Norco (Hydrocodone/Acetaminophen) is a short acting opioid combination pain medication. It is a Schedule II controlled substance that is used to relieve moderate to severe pain. It has a high risk for misuse, abuse and diversion.

4 Benzodiazepines are a class of psychoactive drugs that are a controlled medication. The act as a central nervous system depressant. Nordiazepam, Oxazepam, and Temazepam are not metabolites ofXanax.

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1 Respondent saw W.B. in office and prescribed Xanax and Norco. On April 7, 2014, W.B.

2 provided a urine specimen as part of a random drug screen. On April 9, 2014, the urine drug

3 screen was reported as negative for all controlled substances, including Xanax and Norco. On

4 April 15, 2014, at the next clinical visit, Respondent noted that, "urine drug screen was discussed

5 with patient." Respondent did not note the inconsistent results of the drug screen, took no action,

6 and continued to prescribe Xanax and Norco.

7 57. Between February 12, 2013, and June 8, 2015, Respondent saw Patient W.B. in office

8 for a complaint of "heart pounding" on four separate occasions. Respondent only ordered EKGs

9 and/or thyroid testing. Respondent did not refer W.B. to a Cardiologist or perform any additional

10 cardiac work-ups. Respondent did not document that she was unable to refer W.B. to a

11 Cardiologist or perform any additional work-ups because W.B. was a Medi-Cal patient.

12 Patient V.G.

13 58. Between February 11,2013, and, June 11,2015, Respondent saw Patient V.G. in

14 office for a complaint of "heart pounding" on three separate occasions. Respondent only ordered

15 EKGs and/or thyroid testing. Respondent did not refer V.G. to a Cardiologist or perform any

16 additional cardiac work-ups. Respondent did not document that she was unable to refer V.G. to a

17 Cardiologist or perform any additional work-ups because V.G. was a Medi-Cal patient.

18 Patient L.M.

19 59. On July 30, 2012, Patient L.M. signed a Pain Management Contract with Respondent

20 that stated L.M. would not take illegal substances. On March 5, 2014, Patient L.M. provided a

21 urine sample as part of a urine drug screen. On March 13, 2014, Respondent saw L.M. in office

22 and continued her Xanax and Norco prescriptions. On March 15, 2014, it was reported that

23 Patient L.M.'s drug screen was positive for Carboxy Acid THC, a metabolite of marijuana. On

24 April 10, 2014, at the next clinical visit, Respondent failed to document that L.M. 's urine test

25 indicated that she had used marijuana. Respondent took no action, and continued to prescribe

26 Xanax and Norco. On January 14,2016, at an interview with the Medical Board of California,

2 7 Respondent stated that she must have missed the results of L.M. 's urine screen as her practice

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1 would have been to terminate the patient for failing to follow the terms of the Pain Management

2 Contract.

3 60. Between January 3, 2013, and, December 13, 2015, Respondent saw Patient L.M. in

4 office for a complaint of "heart pounding" on seven separate occasions. Respondent only ordered

5 EKGs and/or thyroid testing. Respondent did not refer L.M. to a Cardiologist or perform any

6 additional cardiac work-ups. Respondent did not document that she was unable to refer L.M. to a

7 Cardiologist or perform any additional work-ups because L.M. was a Medi-Cal patient.

8 61. Respondent's actions represent negligent acts for the following reasons:

9 1. During the treatment of patients R.A., W.B., V.G., L.M., and E.M.,

10 Respondent's failure to accurately document the exams that she was performing by documenting

11 identical patient complaints and identical physical exams, as more fully described in paragraphs 7

12 through 50, represents a departure from the standard of care;

13 2. During the treatment of patients R.A., W.B., V.G., L.M., and E.M., assuming

14 that Respondent was accurately documenting her care of the patients, Respondent's repeated

15 failure to consider, modifY and/or document how each patient was progressing, and/or consider

16 and/or document whether she was considering or modifying treatment for each patient despite

17 repeated identical patient complaints without improvement, as more fully described in paragraphs

18 7 through 50, represents a departure from the standard of care;

19 3. Respondent's failure to investigate or take any action after receiving a urine

20 drug screen that indicated Patient R.A. was taking Benzodiazepines that were not prescribed by

21 Respondent as agreed upon in the Pain Management Contract represents a departure from the

22 standard of care;

23 4. Respondent's failure to refer Patient R.A. to a Cardiologist, failure to do a more

24 substantive cardiac work-up and failure to document why Patient R.A. could not be referred to a

25 Cardiologist and have a more substantive cardiac work-up done represents a departure from the


27 5. Respondent's failure to refer Patient R.A. to a Dermatologist or Allergist,

28 failure to investigate the reason for the recurrent rash despite providing hydrocortisone treatment,

14

(MEET!NDER KAUR RAI, M.D.) ACCUSATION NO. 800-2013-002158

failure to change treatment despite apparent failure, and failure to document why R.A. could not

2 be referred to a specialist represents a departure from the standard of care;


4 drug screen that indicated Patient W.B. was not taking prescribed controlled substances as agreed

5 upon in the Pain Management Contract represents a departure from the standard of care;

6 7. Respondent's failure to refer Patient W.B. to a Cardiologist, failure to do a

7 more substantive cardiac work-up and failure to document why Patient W.B. could not be

8 referred to a Cardiologist and have a more substantive cardiac work-up done represents a

9 departure from the standard of care;

10 8. Respondent's failure to refer Patient V.G. to a Cardiologist, failure to do a more

11 substantive cardiac work-up and failure to document why Patient V.G. could not be referred to a




15 drug screen that indicated Patient L.M. was using illegal controlled substances, specifically

16 marijuana, in conflict with the Pain Management Contract represents a departure from the


18 10. Respondent's failure to refer Patient L.M. to a Cardiologist, failure to do a more

19 substantive cardiac work-up and failure to document why Patient L.M. could not be referred to a



22 THIRD CAUSE FOR DISCIPLINE

23 (Failure to Maintain Adequate and Accurate Records)

24 62. Respondent's license is subject to disciplinary action under section 2266 of the Code

25 in that she failed to maintain adequate and accurate records. The circumstances are as follows:

26 63. Paragraphs 7 through 61 are repeated here as more fully set forth above.

27 63. Respondent's license is subject to disciplinary action under section 2266 of the Code

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15

(MEETINDER KAUR RAI, M.D.) ACCUSATION NO. 800-20I3-002I58

1 because she repeatedly duplicated identical patient complaints and duplicated identical physical

2 exams without documenting the actual exam that she had performed.

3 PRAYER

4 WHEREFORE, Complainant requests that a hearing be held on the matters herein alleged,

5 and that following the hearing, the Medical Board of California issue a decision:

6 1. Revoking or suspending Physician's and Surgeon's Certificate Number A 49556,

7 issued to Meetinder Kaur Rai, M.D.;

8 2. Revoking, suspending or denying approval ofMeetinder Kaur Rai, M.D.'s authority

9 to supervise physician assistants, pursuant to section 3527 of the Code;

10 3. Ordering Meetinder Kaur Rai, M.D., if placed on probation, to pay the Board the

11 costs of probation monitoring; and

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4. Taking such other and further action as deemed necessary and proper.

14 DATED: August_ 30, 2016

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Executive Director Medical Board of California Department of Consumer Affairs State of California Complainant

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filed state of california medical board· of california …4patientsafety.org/documents/rai,...

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